12033_N Tryon Spill Plan 20160106

D-8 Investments, Inc.
Charlotte Distribution Center
2205 N. Tryon Street, Charlotte, NC
Spill Control Guidance Document
And
Spill/Release Response Plan

Purpose
The purpose of this Spill Control Guidance Document and Spill/Release Response Plan (“Plan”) is to describe
measures implemented by D-8 Investments, Inc (“D-8”) and its affiliates to prevent chemical spills from occurring, and
to prepare D-8 to respond in a safe, effective, and timely manner to mitigate the impacts of a spill in the Charlotte
Distribution Center. This Plan is used as a reference for chemical storage information, as a tool to communicate
practices on preventing and responding to spills with D-8 employees and contractors, and as a resource during
emergency response.
Management Approval
D-8 is committed to maintaining the highest standards for preventing discharges of chemicals through the
implementation of this Plan. This Plan has the full approval of D-8 management. D-8’s management has committed
the necessary resources to implement the measures described in this Plan.
Cole Abernathy is the Designated Person Accountable for Chemical Spill Prevention at this D-8 facility and has the
authority to commit the necessary resources to implement the Plan as described.

Designated Person Accountable: Cole Abernathy
Signature: Cole Abernathy
Title: Operations Manager
Date: January 5, 2017

Facility and Business Overview
D-8’s Charlotte Distribution Center is located at 2205 N. Tryon Street, Charlotte, North Carolina 28206, which is
approximately 1.2 miles north of the Charlotte, North Carolina central business district. The facility hours of
operations are 7:30 a.m. to 5 p.m. Monday through Friday. Employees actively engaged in the day to day operations
of the facility include an operations manager, warehouse supervisor and warehouse employee.
D-8 receives finished goods by the truckload at the Charlotte Distribution Center, stores them and then ships them to
customers as they are sold. These goods remain palletized in their original packaging when being stored in the
Charlotte Distribution Center.
Spill Prevention – Storage
All liquid products will be stored in manner that ensures the following are easily identified:
• Product name
• Physical and health hazards
• Manufacturer

All containers (5 gallon buckets or 55 gallon drums) used to store liquid products must include all three pieces of
information listed above in a legible condition or the labels must be replaced as needed.
Additionally, the following storage methods must be utilized for all liquid products containing known contaminants:
• Store all 55-gallon drums of liquid in secondary containment structures. Smaller mobile containers do not
require secondary containment but will be stored inside on concrete floor surfaces.
• Clean and inspect existing concrete secondary containment structures and repair as needed.

Storage is not to be overcrowded and warehouse personnel will ensure racking is sturdy. Additionally, liquid products
will be inspected daily to ensure the containers in which they are stored are not leaking or damaged. Any observed
deficiencies and corrective actions identified during inspections will be documented in the Spill Prevention Inspection
Log in Exhibit A. All products containing known contaminants will be stored in their original packaging or containers
(that is, not used or repackaged) and later removed from the Charlotte Distribution Center in their original packaging
or containers. Known contaminants are listed in Exhibit 2 and Exhibit 3 of the Brownfields Agreement (recorded at
Book 28224, Page 536 of the Mecklenburg County Register of Deeds’ Office) that applies to the Charlotte Distribution
Center and surrounding property. They are attached to this document in Exhibit C for quick reference.
A Facility Map showing the storage area for 55-gallon drums of products containing known contaminants is included
in Exhibit B.
Spill Prevention – Transport
All liquid products will be transported to and from storage areas on pallets by forklift. Liquid products will be securely
fastened to the pallets to ensure no spills occur when transporting products to their storage location or loading them
on trucks for shipment.
Spill Response Preparation – Training
The operations manager will provide spill response training to the warehouse supervisor and warehouse employee.
Training normally includes, but is not limited to: review of these spill response guidelines and procedures, instructions
in spill cleanup techniques and equipment, and review of hazards found in the warehouse which may be of concern
during spill response.
Spill Response Preparation – Hazard Information
Information on the chemical hazards present in the warehouse must be kept up-to-date and readily available.
Sources of information include Material Safety Data Sheets, signs, container labels, posters, and reference books.
The operations manager is responsible for ensuring all this information is readily available for employees.
Spill Response Procedures
In the event of a spill, employees are to proceed with caution, make others aware that a spill has occurred, and
immediately take all appropriate action to prevent, abate, or minimize a release or threatened release of
contaminants. An emergency spill situation exists when there is a high risk to employees, property, or the
environment. In the event of an emergency spill situation, the operations manager must verbally notify the landlord
immediately so the landlord can notify the North Carolina Brownfields Program as appropriate. D-8 is responsible for
notifying any other regulatory authorities as required by applicable law. See contact information for a list of agencies
below.
• Fire Department at 911
• NC Emergency Operations Center [phone]
• EPA National Response Center at [phone]
• NC DEQ Brownfields Program at [phone]
Spill Response Countermeasures
In the event of a minor spill, spill kits will be stored on site to assist with the cleanup process. Upon the occurrence of
a minor spill, the warehouse employee should utilize the spill kit to clean the area in a timely manner. The operations
manager will also notify the landlord even if the spill is only considered minor. In addition to keeping spill kits on site,
all 55-gallon drums of liquid products containing known contaminants will be stored in areas with secondary
containment. Secondary containment must be able to contain 110% of the volume of the largest container. The use of
secondary containers mitigates the risk associated with spillage due to loss of integrity or container failure by
preventing or minimizing the possibility of accidental release of material.

Spill Release/Response Plan

Emergency Equipment at the Facility
D-8 relies primarily upon community provided services for emergency response. Consequently, the variety and
availability of on-site emergency equipment is limited. Response equipment typically present at the facility includes:
• Spill Absorption Material: D-8 usually has on hand a supply of absorbent material in the facility. This
material can be used to dam off the flow of a hazardous material or product containing a known
contaminant. After any release is contained, this material can also be spread over the released liquid until it
has been placed in sufficient volume to absorb it. The contaminated absorbent material should then be
collected and placed in a drum or other containment for proper disposal.
• Personal Protective Equipment: At a minimum, D-8 will keep a supply of goggles, gloves, respirators, and
brooms on hand. This equipment is made available for use when handling hazardous materials and in the
event of a spill or release.
Hazardous Waste Hauler: Under certain conditions, hazardous waste haulers can be of great service
during a release or threatened release of a hazardous material. For example, a hauler can empty a
container that appears to be failing. If a spill is contained, such a service may be able to pump out a
substantial portion of the released liquid. The operations manager will contact an environmental consultant
and/or hazardous waste hauler if such services are necessary.

Spill Containment and Cleanup

• Shut off/eliminate all sources of ignition.
• Attempt to prevent any additional release (if possible). An example would be closing off/sealing/containing a
leaking drum.
• Contain a spill by diking around it using sand or other absorbent material. Ensure special attention to
prevent spilled material from reaching a sewer or storm drain.
• Absorb spilled material using sand or other absorbent material. Floor cleaning/sweeping materials are
appropriate and are made available for spill cleanup.
o Note: It may be possible to pump out a significant portion of contained liquid.
• Avoid skin contact and breathing vapors. Wear appropriate protective clothing and equipment. This
equipment can include chemical resistant gloves, eye protection and respirators.
• Ventilate the area with local exhaust systems or by opening available doors and windows.
o Note: Avoid use of compressed air to speed evaporation of spilled liquid. This practice increases
airborne concentrations and increases the possibility of injuries such as eye damage.
• Dispose of any contaminated absorbent in accordance with applicable regulations. This may involve
disposal of the material as a hazardous waste. If the material is corrosive, place contaminated absorbent
material in polyethylene or polyethylene-lined containers for disposal.
First Aid Procedures
First aid information for an individual chemical is available on its Material Safety Data Sheet. It may also be
appropriate to consult a physician. General first aid responses include:
• Eye Contact: Flush with large amounts of water for at least 15 minutes. Occasionally lift upper and lower
lids. Consult a physician.
• Skin Contact: Remove contaminated clothing and immediately flush contaminated areas with large
amounts of water.
• Inhalation: If overcome or affected by vapors, remove from exposure, and call a physician immediately.
• Ingestion: Call emergency medical aid immediately. Consult MSDS to determine if vomiting should be
induced or if individual should be provided other first aid measures.
Evacuation
The Operations Manager and the Warehouse Supervisor have the authority to direct an evacuation of the facility.
Reporting
• Obligation to Report: Depending upon the volume and material involved, the distribution center may be
required to report a release or threat of release of hazardous material and/or products containing known
contaminants. No report is required for small, non-harmful releases. As noted above, the operations
manager must verbally notify the landlord immediately for all spills or releases (even if they are minor) so the
landlord can notify the Brownfields Program if appropriate. D-8 is responsible for notifying any other
regulatory authorities as required by applicable law. See contact information below.
• Reporting Authority: Employees who detect a release or threatened release of hazardous material or
products containing known contaminants (other than an incidental spill) will immediately notify their
supervisor, who will then be responsible for assessing and beginning a response to the hazard posed. If the
release/threatened release involves a significant volume, the supervisor should promptly notify the
Operations Manager or General Manager who both have reporting authority. If neither of these parties can
be notified, the supervisor has the authority to make the report.
• Reporting Procedure: If uncertain as to whether a report is required, the responsible individual may first
query one of the below listed agencies. If it is determined that a report is required, it will be made to one or
more of the following as required by applicable law:
o Fire Department at 911
o NC Emergency Operations Center [phone]
o EPA National Response Center at [phone]
o NC DEQ Brownfields Program at [phone]
The report will be made as soon as possible if it does not impede immediate control of the release or
interfere with emergency medical measures and will include the following about the release or threatened
release (to the extent known):
o The source and cause of the release
o The exact location and phone number of the facility
o The name of the person that made the report
o The type and quantity of hazardous material(s) involved
o The potential hazard(s) presented (if known)
o The damage or injuries caused by the release
o Actions taken to control or mitigate the release
o Names of other individuals or organizations that have been contacted
• Written Record: A written record of all verbal notifications will be prepared by the reporting individual and
provided to the Operations Manager. This report may be handwritten and will include the following:
o Date and time of call
o Person making call
o Agencies notified
o Individuals contacted
o Summary of conversation(s)
• Brownfields Reporting: In order to maintain a record of any/all spills of over approximately one gallon in
size and/or any spills on the exterior of the building deemed to present a risk to the environment (i.e.,
migration off paved areas or into the storm water drainage system) and action items to clean up the spill (if
any) that may occur during the lease period, the following reporting activities will be prepared and/or
documented:
o The source and cause of the release. o The exact location of the release on the property.
o The name of the person making the report.
o The type and quantity of material(s) involved.
o The potential hazard(s) present (if known).
o Any damage or injuries caused by the release.
o Actions taken to control or mitigate the release.
o Names of any environmental response contractors involved in the cleanup.
o Copies of all disposal manifests, which include disposal location.

I APPROVAL SIG NATURES I
~-----01/05/2017
Property Owner/Landlord Date
Printed Name/Title/Company: Matthew D. Browder I Manager I Summit Avenue Northend, LLC
Co\t-A:bti(vVJt.t.j, Ofe,c.ochcMS MA~~~( 1)-~"[V'-v~3ti:--"'c, 1/5/iot7
Tenant · Date
Printed NamefTitle/Company: .,.,,.,.,
Date
Exhibit A
Spill Prevention Inspection Log
Note to Inspector: Date and sign upon completion of each inspection
Inspection Date Signature Inspection Date Signature Inspection Date Signature

Note to Inspector: Document any storage deficiencies on the form below. (Use additional sheets, if necessary) Be
sure to sign and date each corrective action.
Observed Deficiency Corrective Action

Signature Date

Signature Date

Signature Date

Signature Date

Exhibit B
Facility Map – Materials Storage Area

Materials Storage
Area
Exhibit C
Known Contaminants
(Exhibits 2 and 3 from Brownfields Agreement)

Exhibit 2
The most recent environmental sampling at the Property reported in the Environmental
Reports occurred in February 2011. The following tables set forth, for contaminants present at
the Property above unrestricted use standards or screening levels, the concentration found at each sample location, and the applicable standard or screening level. Screening levels and groundwater standards are shown for reference only and are not set forth as cleanup levels for
purposes of this Agreement.
GROUNDWATER
Groundwater contaminants in micrograms per liter (the equivalent of parts per billion), the standards for which are contained in Title 15A of the North Carolina Administrative Code, Subchapter 2L (2L), Rule .0202, (January 1, 2010 version); or the 2L Groundwater Interim
Maximum Allowable Concentration (IMACs), (April 1, 2011 version):
Groundwater
Contaminant
Sample Location Date of
Sampling
Concentration Exceeding
Standard (µg/L)
Standard
(µg/L)
Benzene DW-2 2/25/2009 3.9 1
Benzene MW-11 6/16/2010 13.9 1
Benzene MW-11D 6/16/2010 3.6 1
1,1-Dichloroethane DW-2 2/25/2009 7.5 6
1,1-Dichloroethane MW-3D 6/16/2010 36.6 6
1,1-Dichloroethane MW-10 2/14/2011 21.1 6
1,1-Dichloroethane MW-11D 2/14/2011 15.6 6
1,2 Dichloroethane TMW-3 6/25/2008 1.37 0.4
1,2 Dichloroethane MW-4 6/16/2010 1.7 0.4
1,2 Dichloroethane MW-7 6/16/2010 2.1 0.4
1,2 Dichloroethane MW-9 2/25/2009 5.6 0.4
1,2 Dichloroethane MW-10D 2/15/2010 111 0.4
Cis-1,2- Dichloroethene TW-DPT-1 7/28/2008 2,930 7
1,1-Dichloroethylene TMW-3 6/25/2008 179 7
1,1-Dichloroethylene TWM-5 6/25/2008 55.3 7
1,1-Dichloroethylene TW-4 8/8/2008 43.9 7
1,1-Dichloroethylene MW-2 11/24/2008 18 7
1,1-Dichloroethylene MW-4 6/16/2010 163 7
1,1-Dichloroethylene MW-6 2/25/2009 208 7
1,1-Dichloroethylene MW-7 2/14/2011 512 7
1,1-Dichloroethylene MW-9 2/25/2009 1,210 7
1,1-Dichloroethylene MW-3D 2/14/2011 4120 7
Groundwater
Contaminant
Sample
Location
Date of
Sampling
Concentration
Exceeding
Standard (µg/L)
Standard
(µg/L)
1,1-Dichloroethylene MW-10 2/14/2011 572 7
1,1-Dichloroethylene MW-10D 2/14/2011 24,600 7
1,1-Dichloroethylene MW-11D 2/14/2011 921 7
1,1-Dichloroethylene DW-2 6/16/2010 16,800 7
1,1-Dichloroethylene RW-2 6/16/2010 10,700 7
Methylene Chloride MW-7 2/14/2011 15.1 5
Methylene Chloride MW-10D 2/14/2011 34 5
Naphthalene DW-2 2/25/2009 9.6 6
Naphthalene MW-10D 2/15/2010 23.9 6
Naphthalene MW-11 6/16/2011 16.6 6
Tetrachloroethylene (PCE) TMW-2 6/25/2008 53.8 0.7
Tetrachloroethylene (PCE) TW-DPT-1 7/28/2008 6,580 0.7
Tetrachloroethylene (PCE) TMW-5 6/25/2008 0.79 0.7
Tetrachloroethylene (PCE) MW-10D 2/15/2010 6.1 0.7
Tetrachloroethylene (PCE) DW-2 2/25/2009 3.6 0.7
Tetrachloroethylene (PCE) RW-02 2/25/2009 1.8 0.7
1,1,1-Trichloroethane MW-4 06/16/2010 260 200
1,1,1-Trichloroethane MW-7 02/14/2011 234 200
1,1,1-Trichloroethane MW-9 06/16/2010 3,260 200
1,1,1-Trichloroethane MW-03D 2/14/2011 1,650 200
1,1,1-Trichloroethane MW-10 02/14/2011 210 200
1,1,1-Trichloroethane MW-10D 02/14/2011 12,800 200
1,1,1-Trichloroethane MW-11D 02/14/2011 651 200
1,1,1-Trichloroethane DW-2 06/16/2010 6,610 200
1,1,1-Trichloroethane RW-2 06/16/2010 18,000 200
Trichloroethylene TMW-2 06/25/2008 27.4 3
Trichloroethylene TW-DPT-1 07/28/2008 1,310 3
Trichloroethylene MW-6 8/19/2009 3.2 3
Trichloroethylene MW-3D 6/16/2010 26 3
Trichloroethylene MW-10D 2/15/2009 49 3
Trichloroethylene DW-02 2/25/2009 24 3
Trichloroethylene RW-2 2/25/2009 16.7 3
Vinyl Chloride TW-DPT-1 07/28/2008 34.5 0.015
Chromium TW-3 08/08/2008 758 10
Groundwater
Contaminant
Sample
Location
Date of
Sampling
Concentration
Exceeding
Standard (µg/L)
Standard
(µg/L)
Chromium TW-4 08/08/2008 209 10
Chromium GP-1W 02/11/2004 2,000 10
Lead GP-1W 02/11/2004 79 15

SOIL
Soil contaminants in milligrams per kilogram (the equivalent of parts per million), the
screening levels for which are derived from the Preliminary Residential Health- Based Soil
Remediation Goals of the Inactive Hazardous Sites Branch of DENR’s Superfund Section (July 2012 version):
Soil
Contaminant
Sample
Location
Depth
(ft)
Date of
Sampling
Concentration
Exceeding
Screening Level
(mg/kg)
Residential
Screening
Level1 (mg/kg)
Tetrachloroethylene SB-6 0-2.5 06/25/2008 35.7 17
Ethylbenzene SA-DPT-9 0-2 06/18/2009 27.4 5.4
Xylenes (total) SA-DPT-9 0-2 06/18/2009 282 130
Chromium B-3 2.5-5 08/08/2008 134 24,000/0.29*
Chromium B-5 15-17.5 08/08/2008 91.8 24,000/0.29*
Chromium B-7 2.5-5 08/08/2008 83.7 24,000/0.29*
Chromium B-10 2.5-5 08/08/2008 52.7 24,000/0.29*
Chromium B-11 5-7.5 08/08/2008 61.5 24,000/0.29*
Chromium B-12 5-7.5 08/08/2008 116 24,000/0.29*
Chromium SA-DPT-1 4-6 06/18/2009 94.5 24,000/0.29*
Chromium RS-DPT-1 10-12 06/18/2009 38.4 24,000/0.29*
Chromium RS-DPT-2 6-8 06/18/2009 84.4 24,000/0.29*
Chromium DPT-BG 3-4 06/18/2009 48.5 24,000/0.29*
Arsenic 3,4 SA-DPT-1 4-6 06/18/2009 2.3 0.39

Notes
1Screening limits displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening limits
displayed for carcinogens are for a 1.0E-6 lifetime incremental cancer risk.
‘*” Screening level for Chromium III compounds/Screening level for Chromium VI compounds
3Screening levels displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening levels
displayed for carcinogens are for a 1.0E-6 lifetime incremental cancer risk.
4 Cited from the July 2012 Guidelines of the Inactive Hazardous Sites Branch (“IHSB”) of DENR’s
Superfund Section as the unrestricted use soil standard because program is most analogous to the
Brownfields Program. The IHSB’s tabulated generic unrestricted use preliminary remediation goal
(“remedial goal” or “screening level”) for arsenic is 4.4 mg/kg. However, the IHSB generic preliminary
remediation goal conservatively assumes the presence of additional soil contaminants that have the same
health effects, a factor not present at this site. The IHSB guidelines also allow for the development of site-
specific remediation goals when appropriate.

SOIL GAS
Soil gas contaminants in micrograms per cubic meter, the screening levels for which are
derived from Residential Vapor Intrusion Screening Levels of the Inactive Hazardous Sites
Branch of DENR’s Superfund Section (July 2012 version):

Soil Gas Contaminant

Sample
Location
Date of
Sampling
Concentration
Exceeding
Screening Level
(µg/m3)
Residential
Screening
Limit1
(µg/m3)
1,1-Dichlorethane VI-3 2/2010 535 150
1,1-Dichlorethane VI-4 2/2010 3,370 150
1,1-Dichloroethylene VI-3 2/2010 65,080 420
1,1-Dichloroethylene VI-4 2/2010 5,080 420
Cis1,2-Dichloroethlyne VP-1 7/22/2009 740 126 3
Tetrachloroethylene VP-1 7/22/2009 31,000 83.4
Tetrachloroethylene VP-2 7/22/2009 3,100 83.4
Trichloroethylene VP-1 7/22/2009 1,800 4.2
1,2,4-Trimethylbenzene VI-7 2/2010 29.9 14.6
Benzene VI-1 2/2010 1,780 31
Benzene VI-3 2/2010 2,830 31
Benzene VI-4 2/2010 212 31
Xylene (mixed) VI-1 2/2010 279 200
n-Hexane VI-1 2/2010 6,370 1,460
n-Hexane VI-3 2/2010 13,900 1,460
1Screening levels displayed for non-carcinogens are for a hazard quotient equal to 0.2. Screening levels
displayed for carcinogens are for a 1.0E-5 lifetime incremental cancer risk.
2standard for trans1,2-dichloroethylene